Document wrpDEOBjYXO741DE0Mp4YvO7o

FILE NAME Reynolds Metals RM DATE 1990 May 9 DOC RM037 DOCUMENT DESCRIPTION Memo RE Asbestos Demolition Repair Procedures " age. Tee file 5/15/90 . MEMORANDUM eye 4 og Barice Barice a cade Barice Barice T. May 9 1990 _ TO Plant Managearnsd Purchasing Agents CC . " FROM RE E. C. Irby J. R. McGill B. J. Sasser L. C. Tropea P. R. Laden B. J. Mallinger A. L. Adams . J. R. Marshburn : Homer M. Cole - Ind Hyg & Tox - 12 ASBESTOS DEMOLITION PROCEDURES RARTARLERETAEREEREELELELELE CKRKKAKLETLELRLEKEERREARERER e Attached Reynolds recently adopted Asbestos - Demolition Procedures These procedures will - apply to all contract fosr asbestos removal work and will be incorporated into a Corporate Operating Manual The procedures '- are detailed but necessary based on a recent incident An asbestos removal company was doing demolition work at one of Reynolds Arkansas facilities A state inspector observed violations of asbestos regulations by the contractor's workers The state contacted the Federal EPA which issued a notice of violation The EPA threatened a lawsuit with a 632,025 fine and an injunction The state sought additional penalties In this type of situation federal law potentially makes both Reynolds and the contractor jointly liable i.e. each liable for the full amount of the fine The EPA took the position . that Reynolds as the larger company was liable for the majority of the fine despite the fafactct the contraccontractor tor completely controlled the work and caused the asbestos violations The case was eventually settled Reynolds paid 75,000 fine to the federal government and a 22,500 fine to the state Reynolds also entered into an agreement with the EPA and the state that requires Reynolds to take additional precaution for future asbestos removal projects Needless to say the EPA and OSHA are now looking over our shoulder make sure Reynolds takes these additional precau- tions To avoid an expensive repetition this incident the attached procedures dealing with the selection and monitoring of asbestos demolition or repair should be implemented immediately Should you have questions regarding attached procedures please call Ed Ron Benton Ext 3795 the implementation of the Marshburn Ext 4056 or Attachment . Homer M. Cole 003610 RECEIVED RECEIVED RECEIVED HAY Ga ree wv o COM 19.62.30 SUBJECT ASBESTOS DEMOLITION REMOVAL AND REPAIR PROJECTS . PAGE : EFFECTIVE of 7 Draft . GENERAL . It is Reynolds Metals Company's policy that all asbestos demolition removal and repair work at company facilities strictly conform with , applicable health and environmental laws and regulations Io ensure ' .. compliance with this policy only contractors approved by Corporate -. - ,. Industrial Hygiene Approved Asbestos Contractors may *? perform asbestos demolition removal and repair work " In addition their . work must be adequately monitored from the time the work commences until wtdll, completion . _ ct ae tee 2 ee must - This procedure outlines the steps which company facilities : follow when selecting and monitoring the work of asbestos demolition -. removal and repair contractors SELECTING ASBESTOS DEMOLITION REMOVAL CONTRACTORS APPROVED ASBESTOS CONTRACTORS - -- ae viveyy Except as provided below in connection with certain exceptional situations all asbestos demolition removal and repair work at company facilities must be performed by Approved Asbestos Contrac- tors Corporate Industrial Hygiene will maintain and provide lists of such contractors to the Corporate Purchasing Department for distribution to facility purchasing representatives In order to be included on this list contractor must possess all required feder- al state and local licenses and certifications and have a demon- of strated history satisfactory performance in asbestos oc .removal and repair projects . demolition EXCEPTIONAL CIRCUMSTANCES company The use of and repair work is circumstances : - employees to perform asbestos demolition removal not encouraged and is restricted to the following ; 1 the time of performance is critical- 2 an Approved Asbestos Contractor cannot be retained on a timely basis - 7 . . 003611 be, ai, oy COM - 19.62.30 SUBJECT ASBESTOS DEMOLITION REMOVAL AND REPAIR PROJECTS . PAGE 2 of 7 EFFECTIVE Draft , 3 the quantity of asbestos or containing material in- volved falls within the EPA's classification of small scale short duration job and 4 -: the demolition or removal material is not the primary of the work For example removal of a valve which is of asbestos or containing purpose but is a necessary component the work consists of the emergency covered with asbestos insulationemergency All employees performing this work must either have successfully completed an EPA approved asbestos supervisor's course or possess a current state asbestos removal license They must also follow the procedures outlined in the 27 1988. . Copies of this Industrial Hygien-e Industrial directive .. Hygiene Directive dated July are available from Corporate . . UNLISTED CONTRACTORS If all of the above conditions are applicable but qualified company employees are not available facility may utilize a contractor who is not on the list of approved contractors provided- the contractor 1- has a demonstrated history of satisfactory experience in asbes-. tos demolition removal and repair project 2 possesses all required licenses and certifications and 3 . completes and submits an Asbestos Demolition Plan Questionnaire prior to commencing work describing how work will be performed Copies of this questionnaire available from Corporate Industrial Hygiene Work the are To the greatest feasible extent the contractor's work shall be monitored in accordance with the monitoring requirements set forth on pages 5 through 7 1 An EPA small scale short duration job involves any a pipe repair of friable asbestos of less than 20 linear feet b repair and removal of friable panel of less than 10 square feet c limited renovation projects of any amount of friable. asbestos and d pipe valve repair or replacement taking less than four hours or involving less than 20 linear feet -003612 SUBJECT ASBESTOS DEMOLITION AND REPAIR PROJECTS - REMOVAL COM PAGE EFFECTIVE 19.62.30 3 of 7 -Draft - AWARDING CONTRACTS aan Contracftosr asbestos demolition removal _ only or repair may be awarded 1. to Approved Asbestos Contractors .* | if the contractor has submitted all of the required tion with its proposal and . documenta- 3 if the contractor's proposal - quirements discussed below complies with the award re- . -, Requests for proposals and i = below -2.. 00. + Loy selection of . . contractors are discussed - - -* * . : o .* tt REQUESTS FOR PROPOSALS = 4 Requests for proposals in connection with removal and repair projects may only be sent asbestos demolition to Approved Asbestos Contractors The scope of work must be included with the request for proposal and must clearly identify the type amount and location of the asbestos and include any additional relevant information regarding the project e - The request for proposal must also include all applicable contract documents including the additional asbestos abatement provisions .which theCorporate Purchasing Department has distributed to purchas- - ing managers and buyers Any exceptions to these contract documents must be approved by the Law Department before contracts are awarded In addition prospective contractors should be directed to all proposed subcontractors in their proposal and should be that they may utilize only subcontractors who are listed by as Approved Asbestos Contractors . identify advised Reynolds Prospective contractors should also be directed to submit the following documentation with their proposals . 1 A completed Asbestos Demolition Contractor Performance Questionnaire This questionnaire is available from Corporate Industrial Hygiene If the contractor intends to use any subcontractors each proposed subcontractor must also complete tractors wish to and return the questionnaire Contractors and " subcon- must complete this questionnaire for each project they be considered for regardless of their status as an Approved Asbestos Contractor : Ae a sb COM 19.62.30 SUBJECT .. ASBESTOS DEMOLITION AND REPAIR PROJECTS REMOVAL . . - -* PAGE 7 . EFFECTIVE 4 of 7 Draft a . A completed Asbestos Demolition Contractor Work . Plan Questionnaire describing how the work will be performed Copies of this questionnaire are also available from - Corporate Industrial Hygiene . : - Pate. * 3 The contractor's contractor's detailed work plan for the project This work plan is in addition to the information submitted on the Work . 4 MEd2ers lt - Plan Questionnaire . . on ee - = Copies of all required contractor and supervisor - licenses for .the contractor and each proposed subcontractor 5. ,6 tt Documentation showing the training and qualifications of individual who Loo project ae - - will be -- collecting air , -. samples hn . for . the the ld . Documentation showing that the laboratory which will be used to analyze air samples is either EPA approved AIHA_certified - . - 7 . . . If the contractor will be using a negative air filtration system evidence that the contractor has obtained a license from GPAC Inc. the holder of the patent on fans used to create negative air pressure the filtered ~ . exhaust SELECTING CONTRACTORS 003614 AWARD REVIEW - Before awarding a contract the facility must .carefully review the contractor's proposed work plan and its complet- ed Work Plan Questionnaire to ensure that its work will comply with all applicable federal state and local laws and regulations . Included in this requirement is compliance with EPA's National Emission StandardSafety for Hazardous Air Pollutions NESHAP . Occupational Safety and Health Administration's regulations and the pertain- ing to asbestos removal The award review must be performed either by a company employee who has successfully completed an EPA approved asbestos supervisor's course outside consultant or by a previously . approved OUTSIDE CONSULTANTS - Corporate Industrial Hygiene will maintain a list of outside consultants who are approved to perform award reviews and monitor contractor performance This list will be supplied to Corporate Purchasing for distribution to facility purchasing representatives Even though a consultant has been approved by Corporate Industrial Hygiene there can be no business affiliation between a consultant and any prospective contractor contractor OTHER APPROVALS -T The facility must ensure that all approvals ~ quired by any other applicable procedures have been obtained re- : SUBJECT . . ASBESTOS DEMOLITION AND REPAIR PROJECTS . REMOVAL COM _ PAGE EFFECTIVE 19.62.30 5 of 7 - Draft _ MONITORING CONTRACTOR PERFORMANCE _ The facility where the work will be performed monitoring the contractor's work to ensure is responsible . ;. for ; 1. it complies with all applicable federal state and local laws . . and regulations and . 2 the approved work plan is being fully carried out The Monitor must be either a company employee who has successfully - completed an EPA approved asbestos supervisor's course or a previous- . ly approved outside consultanats defined above When same nel entering the contractor's safety precautions as are an ~ a : work area the Monitor must follow the required for the contractor's person- FREQUENCY _. The monitoring must start as soon as the contractor enters the work site and must continue until the final clearance air sampling has been successfully completed It is imperative that the Monitor be at the work site and monitor the contractor's performance as frequently as the facility deems necessary to ensure that the contractor com- plies at all times with all applicable laws and regulations ing to asbestos removal Dertain- - ? If monitoring is not performed on continuous basis it must be performed at least once daily for glove bag operations and at least twice daily if there is a containment area If the monitoring is not continuous it should be performed at different times each day in order to limit the contractor's ability to predict when it will * Occur . . DAILY AUDIT REPORT Each day the Monitor must complete either the company's Asbestos Demolition Contractor Performance Audit Report or an alternative document previously approved by Corporate Industrial Hygiene The Audit Report identifies the specific items and areas to be checked by the Monitor each day Copies are available from e ns Corporate of all of Industrial Hygiene Upon completion of the project the Monitor's project reports must be forwarded to copies Corpo- rate Industrial Hygiene for permanent retention PR + viet SUBJECT ASBESTOS DEMOLITION AND REPAIR PROJECTS REMOVAL COM PAGE EFFECTIVE 19.62.30 6 of 7 Draft INDEPENDENT CONTRACTOR RELATIONSHIP In order not to jeopardize the independent between the contractor and the company the 1. tell the contractor how to perform the contractor relationship Monitor shall not work or * 2 exercise any control over the contractor's , employees Except when immediate action or attention is imperative the- must direct all communications to either the contractor's manager or its project representative Monitor projec.t. IMPROPER WORK PRACTICES The Monitor must immediately direct the contractor to stop any work _ 7 practice or situation such as a breach in a containment barrier inadequate worker decontamination or a breakdown of the negative air machines which the work place work to resume could result in therelease of asbestos fibers into or environment The Monitor should not permit the until the contractor has corrected the practice or situation All such incidents must be documented in the Monitor's daily monitoring log WORKER CERTIFICATION wee employee = -No individual whether an of the contractor or any subcon- -No tractor should be permitted to perform any work in connection with the project until the contractor submits documentation to the Monitor - which 1 documents that the individual has months been . the last 12 and medically examined within 2 indicates whether the examining physician detected a medical condition that would place the individual at an increased risk of health impairment from exposure to asbestos No individual who would be placed at an increased impairment from exposure to asbestos may perform any tion with the project until the contractor also Monitor risk of work in submits health connec to the 6 1 evidence that the individual has been fit tested with negative te pressure respirators within the last six months and aot. 2 a physician's written opinion that there are no limitations on oe the individual's use of respiratory protection ie 003616 ~F SUBJECT ASBESTOS DEMOLITION REMOVAL AND REPAIR PROJECTS - COM . . PAGE 19.62.30 7 of 7 EFFECTIVE Draft . : In addition no individual should be permitted to perform work on the project until the contractor submits a copy of the individual's asbestos worker license If the state in which the work is being performed does not require asbestos worker licenses the contractor must submit evidence that . the individual has successfully completed an EPA approved asbestos worker training course . - . SAMPLES + The Monitor must collect at least two area air samples each day - at the entrance of the clean room and another at the exhaust of the ~ , negative air machines If a regulated area has been established the . Monitor must - -collect at least one air sample daily at the boundary between the regulated area and the normal work area If any air sample reveals asbestos levels at or above 0.1 cc the Monitor shall direct the contractor to stop the demolition removal or repair work immediately The Monitor shall not permit the work to resume until the contractor has modified the project work practices to reduce the asbestos air levels to less than 0.1 cc FINAL INSPECTION -. ~~ After the asbestos demolition removal or repair project including final cleanup has been completed the Monitor must conduct a visual inspection of the work area This inspection must take place before final clearance air sampling and must include entry into the work area to visually check for contamination on surfaces from which containing material has been removed Additionally the Monitor must inspect for containing material other surfaces which hainspev ct hae ve been any asbestos caught on or asbestos- equipment Or ton Once the work area has passed the Monitor's visual inspection the final clearance air sampling must be performed The project will be deemed to be complete when aggressive air sampling shows airborne asbestos levels of 0.01 cc or less If there are any questions inspection the Monitor Industrial Hygiene concerning the daily monitoring should promptly consult with - or final Corporate